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Second, section 1847A(c)(5)(A) of the Act requires each manufacturer to apply a methodology based on a 12-month rolling average for the manufacturer to estimate costs attributable to price concessions if there is a lag in the reporting of the information on rebates and chargebacks ( under section 1847A(c)(3) of the Act

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ROS are also generated by non-mitochondrial sources such as the nicotinamide adenine dinucleotide phosphate oxidase (NOX) and NOX homologs, ROS-generating enzymes, and the -oxidation of fatty acids in the peroxisome